[SLVRCLIST] FCC REFUSES PETITION TO EXPAND 2 METER REPEATER SUBBANDS FOR DIGITAL OPERATIONS

[Tim Pekkonen]

Hi folks;

I pulled this off the Frequency Coordinator's Yahoo Group, as the SLVRC is
wrestling with this issue. It looks like our policy which was determined at
last Spring's SLVRC meeting will be in force for a while yet.

73 Tim VE3UO
Chairman, SLVRC


LOOKING WEST:  THE VHF  FM AND REPEATER COLUMN
WorldRadio Edition 115 - July 2008
By Bill Pasternak, WA6ITF


FCC REFUSES PETITION TO EXPAND 2 METER REPEATER SUBBANDS FOR DIGITAL OPERATIONS

Dateline Washington D-C where the Federal Communications Commission on May
7th denied a petition filed by two California hams asking that an
additional repeater subband be created on 2 meters.  This, ostensibly to
permit the introduction of digital voice repeaters in areas where no
spectrum exists for them.

In the petition for Rule Making filed last October 10th, Ken D. Chafin,
W6CPA, and Leon J. Brown, KC6JAR, Commission amend its rules to allow
repeater stations to transmit in the 145.5 to145.8 MHz segment of the 2
meter amateur band.  This, in addition to the 2 meter frequency segments
currently authorized for repeater station operation.  In their petition
Chafin and Brown argued that additional spectrum is needed for repeater
stations because some amateur repeater stations have begun using certain
digital communication protocols, and "digital voice operation is
incompatible with existing analog operations .  This, because digital voice
users are unable to determine if the desired frequency is in use by analog
users and can inadvertently cause harmful interference to those users.  The
pair also argued that coordinating groups have been unable to separate
analog and digital voice repeater operations to avoid harmful interference
because the available repeater spectrum in the 2 meter band is fully
occupied by existing analog users in most metropolitan areas."

After consideration of their request, the agency concluded that the
Petition does not present grounds for the Commission to propose to amend
its rules.  That repeater stations are authorized to transmit on any
frequency in the 2 meter band except the 144.0 to 144.5 MHz and 145.5
to146.0 MHz frequency segments.  These two segments were excluded to
minimize the possibility of harmful interference to other amateur service
stations and operating activities, especially "weak
signal"  operations.  The FCC says that allocating an additional three
hundred kilohertz of the 2 meter band to repeater operation would not be
consistent with that concern.  Rather, it would likely result in increased
interference to non-repeater stations.

Moreover, to the extent that the petition proposes a separate frequency
segment for use by digital but not analog repeater stations, the FCC note
that when the Commission has previously addressed the issue of interference
between amateur stations engaging in different operating activities, it has
declined to revise the rules to limit a frequency segment to one emission
type in order to prevent interference to the operating activities of other
amateur radio service licensees  Rather, the Commission noted that
interference between amateur stations is already addressed by Section
97.101(b) and (d) of the Commission's Rules.  These require amateur
licensees to cooperate in selecting transmitting channels and in making the
most effective use of amateur frequencies, provide that no amateur
frequency will be assigned for the exclusive use of any station allocated
to the Amateur Radio Service, and prohibit operators from willfully or
maliciously interfering with or causing interference to any radio
communication or signal.

The bottom line.  The FCC says no new repeater subband will be created to
cater to the desires of digital voice operators.  Rather, those wanting to
use this or any other emerging modes will have to do so within the context
of the existing Amateur Services rules. Rules that say repeaters, be they
analog or digital have to stay in their own R-F back yards and operate in a
way as to cause no interference to other users of bands where repeater and
non repeater operations both exist.  It also might be viewed as a kind of
subliminal warning to coordinators who are considering putting digital
voice repeaters in spectrum outside of established repeater subbands to
reconsider and not make such a move.

**

SO WHAT DOES IT MEAN TO YOU AND ME

Now that thew FCC appears to have made it clear that its not going to
expand repeater subbands to placate the needs, wants and/or desires of
proponents of digital voice repeaters to give them a foothold on spectrum,
just how can they survive and prosper.  And what does it mean to you and me?

The technologic answer is very simple but the sociological and political
implications are a lot more far ranging.  If you look at who wants to put
up digital voice repeaters its mainly those who already own and operate one
or more analog FM machines.  Some individuals and clubs around the country
operate analog voice repeaters on every band from 6 meters through 1.2 GHz
or higher.  Others have both voice and ATV systems on several bands.  Each
of these repeaters ties up a pair of channels on each band, but since the
latest round of restructuring that has siphoned off many former VHF /
UHF-only operators to HF, more and more repeaters are lying dormant for
days and even weeks at a time.

So heres the first part of the solution:  If you fall into the category of
multiple repeater ownership, you should not be going back to the local
frequency coordinator asking for more frequency pairs so you can own yet
another repeater.  Straight out -- that's being a spectrum hog!  Instead,
convert one or more of the systems you now own from analog to digital.

"Oh wait" you say.  "What about my users who do not want to go
digital?  What will happen to them?"

Well that's the sociological and political aspect of this
situation.  Chances are that those who operate one-band only and if it's
the band you plan to take digital will be lost.  They won't be giving up
the hobby but instead will simply move to another analog FM
repeater.  Consider it part of the cost of modernization and move on.

So it becomes a question that you as a repeater owner operator have to
make.  Are you willing to forgo advancing to a new technology to placate
the wants and desires of a current user base?  Or are you willing to accept
some loss in the number of folks using your repeater in exchange for being
a state of the art relay device.

Then there is the argument always put forth by owner/operators of multiple
repeaters that they need to have all of them ready in case one fails during
an emergency.  The truth be known, unless the repeaters are each at
different sites, in an emergency situation the chances are that all
repeaters located at a single (common) repeater site will be knocked off
the air.  So if you want to raise this argument, then you had better show
that your system on 2 meters is at a different location from your 220 MHz
or 440 MHz repeater and all sites had better have some form of emergency
back-up power.  With spectrum being a finite resource and there not being
very much of it left in most urban areas, one person or one club owning and
operating a large number of analog machines while trying to grab spectrum
for a new set of digital machines is more than just inappropriate.  In my
book its downright wrong-headed and needs to be stopped before it becomes
widespread.

What about the new want-to-be digital voice repeater owner?  The individual
or new club who goes to the local repeater coordinator only to find that
there are already a dozen or so folks ahead of him, most already waiting a
few years for a channel pair for a new analog FM system?  Sorry, but you go
to the back of the line.  The fact that you may have the money the buy and
install the latest and greatest of digital voice equipment does not give
you any special right to jump ahead of  someone who mat have been waiting
patiently for years and playing by the rules.  It just means you have
money, and nothing more.  Forcing yourself on the local ham community to
satisfy the craving of your personal or organizational ego is not going to
win you any friends -- be they Analog or digital enthusiasts.

Lastly, this note to those few coordinators and coordination councils who
believe that they can circumvent the rules by defining digital voice
repeaters as something other than a repeater so as to place them into
spectrum outside repeater subbands.  Calling them non-repeaters because
there is a technical albeit miniscule time lad between the input and output
due to the analog to digital conversion process.

Well, I am not an expert on communications law, but I do know about
ducks.  And if it waddles like a duck and quacks like a duck, the chances
are that it's a duck.  Likewise if you talk with a radio on a repeater
input and what you have said appears on the repeaters output -- in analog
or digital form -- then it's a repeater.  So stop trying to play like
D-Star and P25 machines are not repeaters and get on with the job of
coordinating them where they belong.  That being within the confines of the
various designated repeater subbands.

Oh yes, here's one incentive you might not have yet thought about:  If some
guy puts his repeater outside the repeater subband because the coordinator
told him to do so gets a citation or fine from the FCC, guess who is going
to hear from the guys lawyer. We all know just how litigious today's
society is.  Keep that in mind before you go out and bend the rules just to
squeeze in a new digital voice repeater or anything else under the guise of
it "…not being a repeater" when we all know that it is.

**

De WA6ITF




-- 
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Tim Pekkonen VE3UO
tim.ve3uo at gmail.com
Belleville ON FN14hd
* * * * * * * * * * * * * * *
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